Margaret Corkrean v. Drake University, No. 22-1554 (8th Cir. 2022)
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Plaintiff, a former employee of Drake University (Drake), brought this action against Drake and her former supervisor, (collectively, Appellees), after her 2019 termination. Plaintiff alleged disability discrimination, hostile work environment, and retaliation under both the Americans with Disabilities Act (ADA) and the Iowa Civil Rights Act (ICRA), as well as retaliation and discrimination based on the exercise of her rights under the Family Medical Leave Act (FMLA). The district court granted summary judgment in favor of Appellees on all of Plaintiff’s claims. On appeal, Plaintiff challenged the district court’s grant of summary judgment on her retaliation claims under the FMLA, ICRA, and ADA, as well as her discrimination claim under the FMLA.
The Eighth Circuit affirmed. The court explained that here, Appellees have established a robust, well-documented set of legitimate reasons for Plaintiff’s termination—and Plaintiff does not dispute them. These reasons include a plethora of performance deficiencies, such as failing to pay staff members the appropriate amounts and missing deadlines, as well as non-FMLA tardiness and attendance problems. Here, the only evidence of pretext Plaintiff provides is: (1) a tenuous temporal connection between her harassment complaints and negative performance reviews; (2) a one-month temporal connection between her filing an NLRB complaint and her termination; and (3) Drake’s failure to follow its harassment-complaint policies. Therefore, the court held that Plaintiff’s FMLA claims fail as a matter of law because she has presented insufficient evidence of pretext.
Court Description: [Shepherd, Author, with Smith, Chief Judge, and Benton, Circuit Judge] Civil case - Employment discrimination. With respect to plaintiff's FMLA retaliation and discrimination claims, assuming without deciding that plaintiff made a prima facie case, the University established a robust, well-documented set of legitimate performance-related reasons for plaintiff's discharge, and she has failed to show that these legitimate non-discriminatory and non-retaliatory reasons were pretextual; while deviations from employment policies can create a material fact question on the issue of pretext, Drake's deviations from its policies were technical and slight and did not support a finding of pretext; assuming that plaintiff can establish a prima facie case of retaliation under either the ADA or the Iowa Civil Rights Act, her claims fail on the same pretextual hurdle described above. [ December 12, 2022 ]
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